GSTR-9 Annual Return for FY 2025-26: Due Date, Exemptions & Compliance Checklist

The clock is already running on the GST annual return for FY 2025-26. Form GSTR-9, and where applicable Form GSTR-9C, must be filed by 31 December 2026, and past filing seasons show that businesses which start reconciling early avoid late fees, notice replies, and last-minute portal congestion. This is also a good time to check whether your business actually needs to file at all, since a continuing CBIC exemption keeps a large number of small taxpayers out of the annual return altogether.

What Are GSTR-9 and GSTR-9C?

GSTR-9 is the consolidated annual return required under Section 44 of the CGST Act, 2017 read with Rule 80 of the CGST Rules. It summarises, for the entire financial year, the outward and inward supplies declared, taxes paid, and input tax credit (ITC) availed and reversed across the monthly or quarterly returns already filed (see ClearTax's GSTR-9 guide).

GSTR-9C is a reconciliation statement that matches the figures declared in GSTR-9 against the taxpayer's audited financial statements. Since the 2021 amendment to Section 35(5), it no longer requires certification by a chartered accountant — it is self-certified by the taxpayer (see ClearTax's GSTR-9C guide), though most businesses still engage a professional to prepare it accurately.

Due Date for FY 2025-26

Under Section 44(1) of the CGST Act, the annual return for a financial year is due by 31 December following the end of that year. For FY 2025-26, the due date is therefore 31 December 2026, unless CBIC issues a further extension closer to the deadline, as it has done in some past years. It is worth building your compliance calendar around this date now rather than waiting for a possible extension.

Who Must File — Turnover Thresholds

Applicability depends entirely on your aggregate annual turnover during the financial year:

Exemption for Small Taxpayers (Turnover up to ₹2 Crore)

Vide Notification No. 15/2025-Central Tax dated 17 September 2025, issued under the first proviso to Section 44(1) of the CGST Act, CBIC exempted registered persons with aggregate turnover up to ₹2 crore in a financial year from filing GSTR-9. This exemption applies from FY 2024-25 onwards, so it continues to cover FY 2025-26 as well (see TaxGuru's analysis of the notification). Composition taxpayers, casual taxable persons, input service distributors, non-resident taxable persons, and persons liable to collect TCS under Section 52 also remain outside the GSTR-9 filing requirement, regardless of turnover.

Mandatory Filing Between ₹2 Crore and ₹5 Crore

Once aggregate turnover crosses ₹2 crore in the financial year, filing GSTR-9 becomes mandatory. GSTR-9C is not required at this level.

GSTR-9C for Turnover Above ₹5 Crore

Registered persons whose aggregate turnover exceeds ₹5 crore during the financial year must file both GSTR-9 and the self-certified reconciliation statement GSTR-9C. Since this statement is reconciled against audited books, it is best prepared alongside your statutory or tax audit rather than as an afterthought.

Late Fees for Missing the Deadline

Delayed filing attracts a late fee under Section 47 of the CGST Act of ₹100 per day under CGST and ₹100 per day under the corresponding SGST/UTGST law (₹200 per day in total), subject to a cap linked to a percentage of the taxpayer's turnover in the relevant state or Union Territory. Interest may also apply separately on any additional tax liability identified through the reconciliation. Given that the late fee runs daily, even a short delay can add up meaningfully for larger taxpayers.

Practical Checklist for Businesses and Tax Professionals

• Confirm your applicable turnover slab (exempt, GSTR-9 only, or GSTR-9 plus GSTR-9C) based on aggregate turnover for FY 2025-26.

• Reconcile figures across GSTR-1, GSTR-3B, and your books of account before populating GSTR-9.

• Match ITC claimed during the year against GSTR-2B to identify and correct mismatches.

• Verify HSN/SAC-wise summary reporting and outward supply classifications for accuracy.

• If turnover exceeds ₹5 crore, align GSTR-9C preparation with your statutory or tax audit timelines.

• Retain supporting documentation — invoices, credit/debit notes, and reconciliation working papers — for future scrutiny.

• File well ahead of 31 December 2026 to avoid portal congestion, data-entry errors, and daily late fees.

Conclusion

The GST annual return is one of the few compliance touchpoints that forces a full-year reconciliation of your GST position, making it a valuable health check even where filing is optional. Understanding whether you are exempt, whether GSTR-9C applies to you, and starting reconciliation early are the three decisions that matter most this filing season.

This article is intended for general awareness and does not constitute personalised tax advice. For a review of your specific GST annual return obligations for FY 2025-26, or assistance preparing and filing GSTR-9 and GSTR-9C, contact CA Samir K. Mehta & Associates — our team can help you confirm applicability, reconcile your data, and file on time.